GR 172875; (August, 2007) (Digest)
G.R. No. 172875 ; August 15, 2007
PEOPLE OF THE PHILIPPINES, Appellee, vs. DANIEL PEREZ y BACANI, Appellant.
FACTS
The appellant, Daniel Perez, was charged with the rape of AAA, his neighbor, on January 27, 1998, in Antipolo City. AAA testified that between midnight and 12:30 a.m., she was awakened in her home by Perez, who held a knife to her back and threatened to kill her if she made noise. He then molested her inside the house. When her 12-year-old son, BBB, was awakened, Perez dragged AAA outside to a mango tree, where he forcibly had sexual intercourse with her. AAA managed to throw away the knife during the struggle but was caught when she attempted to flee. After the act, she immediately reported the incident to the police. Her son, BBB, corroborated her account, stating he saw a shadow and heard the threats and pleas, and later saw Perez on top of his mother outside.
The defense presented an alibi, with Perez claiming he was at home with his family and could not have committed the crime. He argued that the charges were fabricated due to a land dispute with AAA’s family. The medico-legal report presented by the prosecution documented multiple abrasions on AAA’s body, consistent with physical struggle.
ISSUE
The core issue is whether the prosecution proved beyond reasonable doubt that Daniel Perez committed rape through force and intimidation.
RULING
The Supreme Court affirmed the conviction. The Court emphasized that the credibility of the victim’s testimony is paramount in rape cases. AAA’s detailed and consistent narration, corroborated by her son’s eyewitness account and the medico-legal findings of abrasions, firmly established the occurrence of sexual intercourse through force. The Court found her actions after the incident—immediately reporting to the police—to be natural and indicative of a truthful claim.
The defense of alibi was rejected as inherently weak and could not prevail over the positive identification by the victim. The alleged motive of a land dispute was deemed insufficient to explain why a mother would subject herself and her child to the ordeal of a public trial and falsely accuse a neighbor of a grave crime. The Court held that the prosecution successfully proved all elements of rape: carnal knowledge by the accused, accomplished through force or intimidation, and without the victim’s consent. The decision of the Court of Appeals affirming the penalty of reclusion perpetua was thus upheld.